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In tax law, the principle dictates that tax follows the legal form of a transaction unless specific anti-avoidance provisions apply or if the transaction is deemed a sham. For example, section 7C outlines scenarios where tax consequences arise. Regarding loan accounts, the South African Revenue Service (SARS) can disregard a transaction as a loan only if it fails to meet the common law criteria for a loan agreement and is intended to serve a different purpose. SARS cannot mandate the charging of interest; they can only impose tax consequences through anti-avoidance measures for interest-free loans. A valid loan agreement requires a clear obligation to repay a specified amount.